Finding Text
2024 – 004
Federal Agency: Department of Education
Federal Program Name: Higher Education Aid – Title III
Assistance Listing Numbers: 84.031
Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2023-24 award year.
Award Period: July 1, 2023, through June 30, 2024
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Condition:
During our testing of suspension and debarment, we noted the University did not have support for debarment checks five of the five vendors tested.
Questioned Costs:
N/A
Context:
During our testing of suspension and debarment, we noted the University was unable to provide support for debarment checks five of the five vendors tested.
Cause:
The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for five of the five vendors selected.
Effect:
Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring.
Repeat Finding: Yes – 2023-005.
Recommendation:
The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.
Views of responsible officials:
Management agrees with the findings and has developed a plan to correct the finding.